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Sevier County Commision Letter, Aug. 13, 2012

Sevier County Commision Letter, Aug. 13, 2012

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This is the letter Dick Cumiskey, president of Sevier Citizens for Clean Air and Water, planned to deliver to the county commission on Monday and the health department on Thursday.
This is the letter Dick Cumiskey, president of Sevier Citizens for Clean Air and Water, planned to deliver to the county commission on Monday and the health department on Thursday.

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Published by: The Salt Lake Tribune on Aug 13, 2012
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SEVIER CITIZENS FOR CLEAN AIR AND WATER, INC.
146 North Main, Suite 27P.O. Box 182Richfield, Utah 84701435-527-4448
August 13, 2012Sevier County Commission250 N Main St.Richfield, Utah 84701Dear Commissioners, Two years ago, you, the Sevier County Commission embarked on a majorproject to create a PUD for Sevier Power Company. At that time you invitedSevier Citizens for Clean Air & Water to offer suggestions that might beincorporated into that PUD. We did offer suggestions and recommendationsand many of these were ultimately made a part of that PUD. The process of collaboration worked. SCCAW is grateful for that opportunity and we thank youfor it.Here we are two years later and Sevier Power is still struggling with theirapplication for an Air Quality Permit from UDAQ. Twelve years have nowelapsed since the project was initially proposed. Is this any way to run abusiness? To our knowledge Sevier Power still does not have a source of natural gas with which to fuel the power plant, does not have a permit toconnect to the Rocky Mountain Power substation in Sigurd, has not applied fortransmission capability, does not have a customer to purchase the powergenerated and, without all of the above, does not have financing with which toconstruct the plant. Homer Simpson could have done a much better job.On Thursday, May 31, we all sat through a Public Hearing, scheduled by UDAQ,to voice our concerns about the draft Air Quality Permit for Sevier Power. Anumber of significant issues were raised at this hearing. First and foremost isthe issuance of pollution allotments to Sevier Power based upon the“assumption” that the air within Sevier County is “in attainment”. This is ageneral term used by the department to classify any air shed of which theyknow little or nothing. Think about this for a minute. Sevier Power is asking for the right to pollutewith regulated noxious airborne chemicals to the extent of 977 tons per year
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(tpy) plus 2,019,226 tpy of greenhouse gases for a period of 40 years. UDAQ isready to approve this huge increase in our pollution level without even takingthe time to investigate the existing condition of our air. They are not evenmaking a SWAG (scientific wild ass guess). Does this make any sense to you?It certainly does not make sense to SCCAW.Assuming that UDAQ might be correct in their guess about the existing airquality of Sevier County, the amount of pollution issued to Sevier Power willcome close to the threshold that would soon place Sevier County in a non-attainment status, just as counties along the Wasatch front are now. Shouldthe air be found to not be as clean as assumed, then we could already be innon-attainment status. Is this what we want for Sevier County?When the air quality is approaching the limit of an “attainment” area, what isleft for other businesses that we might wish to attract to our county? Somepeople have said that having a power plant here in the valley will attract otherbusinesses requiring large amounts of power. What ones do you know thatdon’t also contribute large amounts of pollution. Could they even get an airquality permit with the increments already spoken for? Think about it. ShouldSevier County reach non-attainment status, we could lose our ability to attractnew businesses.Our current mining and trucking industries may be negatively impacted if there is insufficient pollution increments left after permitting SPC. Currentguidelines state that any proposed consumption of increments of pollutionshould be effectively utilized by the applicant and should not needlessly tie upincrements from use by others. Sevier Power Company has been in theapplication process for a power plant in one form or another since 2001. Thereis no indication that this application is any more viable than their previousapplication. There well may be other applicants, in any number of otherindustries, that might want to take advantage of these increments should theybe tied up. It is certainly in the best interests of the UDAQ, the State of Utahand Sevier County to protect incremental consumption for use in viableprojects. The following is a quotation from the Utah Supreme Court decision in whichthe air quality permit for Sevier Power Company was sent back to the divisionfor additional work:
“Instead, Utah rule 307-401-11 governs theenforcement of Utah’s PSD program, which was approved by the EPA.This enforcement rule, as approved by the EPA, must beinterpreted to achieve the same goals as the federal PSD program.These goals include ensuring that a new emitting source is
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constructed with the most current control technology and that aPSD permit for a new source does not tie up PSD increment limitsunnecessarily. The Board failed to interpret the rule to achievethis goal when it - - -“
Our primary concern now is that no one really knows what the year roundstatus of the air in Sevier County is. In addition to periodic wildfires,agricultural burns, truck and heavy equipment exhaust, agricultural dust andother permitted mining dust we also have frequent, and sometimes lengthy,inversions – all year round. Don’t you think we should know what our airquality really is? Don’t you think we have the right to know? SCCAW believesboth of these questions are pertinent, and that is why they were raised at thePublic hearing – and are being raised now.SCCAW is asking you, the Sevier County Commissioners, to take an active rolein demanding that UDAQ , either themselves or through the permit applicant,undertake an EPA recommended study to determine the actual levels of pollution for a period of at least one year before finalizing any permit forSevier Power. Actual data must be collected to protect the health of thepopulation as mandated by the federal Clean Air Act (CAA). You have a duty tothe citizens of this county to avoid any undue risks to the health and welfare of all of our citizens. Over 700 residents of Sevier County are now onsupplemental oxygen and any reasonable physician will acknowledge thereare likely two to three times that number with other respiratory and cardiacproblems that will be amplified by the increase in air pollution.SCCAW also requests that Sevier County’s representative to the Central UtahBoard of Health request that CUPHD also make the same request of UDAQ.Remember, this permit is good for 40 years, the expected life of the plant. Thisplant could easily outlive every one of us here in this room today. This plantwill not only have an impact on you and I, it will be a legacy for our childrenand grand children. The quotation below is taken directly from the home page of the Central UtahPublic Health Department’s website.Central Utah Public Health Department (CUPHD) was established in 1973 with a missionto improve and protect the health of all citizens in the six-county area by offeringservices that enhance the environment, prevent illness and injury, and promote healthylifestyles. Central Utah Public Health provides services to a growing population of over
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